As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) of the Internal Revenue Code (the Code) provides that a taxpayer’s interest expense is deductible only to the extent of the sum of: (i) the taxpayer’s interest...more
1/27/2021
/ Biden Administration ,
CFCs ,
Coronavirus/COVID-19 ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Regulatory Freeze ,
Subpart F ,
Tax Cuts and Jobs Act ,
Taxable Income ,
U.S. Treasury
On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-127732-19) (the 2020 Proposed Regulations) that would conform the historic Subpart F...more
8/7/2020
/ CFC ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Federal Trade Commission (FTC) ,
GAAP ,
GILTI tax ,
IFRS ,
Income Taxes ,
IRS ,
New Rules ,
Proposed Regulation ,
Shareholders ,
Subpart F ,
Tax Cuts and Jobs Act ,
Tax Rates ,
U.S. Treasury
Final and new proposed regulations on the base erosion anti-abuse tax (the BEAT) under section 59A have been issued by the United States Treasury and IRS, providing clarifications and some relief tied to inbound liquidations...more
12/18/2019
/ Anti-Abuse Rule ,
Base Erosion and Anti-Abuse Tax (BEAT) ,
Base Erosion Tax ,
Business Judgment Rule ,
Corporate Taxes ,
Final Rules ,
GILTI tax ,
Income Taxes ,
IRS ,
New Regulations ,
Popular ,
Proposed Regulation ,
Revenue Procedures ,
Subpart F ,
Treasury Regulations
Health Care Private Equity Investments in India -
A flurry of recent private equity (PE) investments in the Indian health care sector demonstrates strong investor appetite and opportunities.
India is one of the fastest...more
New section 59A imposes a minimum tax on domestic corporations with substantial amounts of deductible payments made to related foreign persons (referred to as the base erosion and anti-abuse tax, or BEAT). The BEAT can apply...more
The 2017 tax act expanded Subpart F to require an inclusion in income of “global intangible low-taxed income” (GILTI) of a controlled foreign corporation (CFC). This is generally the amount of a CFC’s income in excess of its...more